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above within the boundaries of their charge, and only as long as
they are licensed by the Church to do so.
Petitioner's annual earnings from performing as a local
pastor the services described above exceeded $400 in 1983 and
1984.
The application for exemption from self-employment tax
contemplated by section 1402(e) is embodied in Form 4361,
"Application for Exemption from Self-Employment Tax for Use by
Ministers, Members of Religious Orders, and Christian Science
Practitioners". In addition to other information, an applicant
for exemption must report on that form: (1) The date that the
applicant was "ordained, licensed, etc." (line 3); and (2) the
first 2 years after the date listed on line 3 that the applicant
had "net self-employment earnings of $400 or more, any part of
which came from services as a: minister, priest, rabbi, etc."
(line 5).
On April 17, 1989, petitioner filed a Form 4361. On that
form petitioner indicated that the date he was "ordained,
licensed, etc." was May 25, 1987 (the date that he was ordained a
deacon). He reported that 1988 and 1989 were the first 2 years
after the date of his ordination in which he had "net self-
employment earnings of $400 or more, any part of which came from
services as a: minister, priest, rabbi, etc." Relying upon the
information reported on the form, on April 9, 1990, respondent
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